Ethics and Compliance
Launched in 2021, the Ethics & Compliance Program is designed to enhance our approach to promoting ethics and integrity, principles which have always been part of our company's management model. Vale annually reports on progress in a voluntary annual report describing our compliance processes, the outcomes of training and communication initiatives, and key statistics from our Whistleblower Channel.
The 6 elements of our Ethics and Compliance Program
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Autonomy, independence and tone from the top: Vale's Ethics & Compliance Program governance is structured to ensure that the entire organization is committed to our ethical principles.
The Audit and Compliance Department is responsible for the Program. Reporting directly to the Board of Directors, and with further oversight from the Audit and Risks Committee, the department works in partnership with the Conduct and Integrity Committee.
This governance structure is designed to ensure impartiality and prevent conflicts of interest. Through periodic external audits, the Audit and Risks Committee assesses Program effectiveness every two years and contributes to its ongoing improvement.
Translating our values into ethical principles and clear rules: this is the main objective of the Guidelines of the Ethics & Compliance Program.
Our Code of Conduct established the ethical principles that must guide the conduct of everyone who works at Vale. The document is available in eight languages as well as in audiobook format for people with visual disabilities. The Code applies to Vale and our subsidiaries across the globe. We also encourage companies in which we hold a stake to adopt similar principles (see Joint-ventures management).
We also share our values and ethical principles with our suppliers and other third parties through our Principles of Conduct for Third Parties.
Key public policies on ethical conduct for Vale and our suppliers and contractors:
• Code of Conduct
• Principles of Conduct for Third Parties
• Global Anti-corruption Policy
• Anti-Corruption guide for suppliers and other types of third parties
• Consequence Management Policy
Communication & Training
Our ethical principles need to be communicated, understood and put into practice by everyone who works at Vale. This is the objective of the Communication & Training actions.
For each audience, a different approach. Customization is an essential part of our Communication & Training strategy. With global initiatives and specific actions for employees who are more exposed to risks, the Ethics & Compliance Program seeks to guide everyone on how to make decisions in an ethical and responsible way.
We provide annual updates on our training initiatives in our Ethics & Compliance Program Report.
Risks & Monitoring
We manage ethics and compliance risks through an integrated Risk Management and Governance framework based on the Lines of Defense model.
The role of each Line of Defense in our Ethics & Compliance Program
The 1st Line of Defense — which is directly responsible for our operations or administrative functions—works to implement effective prevention and mitigation controls and ensure that corrective action plans are adequately established and implemented to continuously improve our risk management processes.
Corporate Integrity works as the 2nd Line of Defense and is responsible for managing ethics and compliance risks. This Line of Defense defines methodologies, minimum technical and management standards, and mandatory risk indicators to be adopted by the 1st Line of Defense.
Our Whistleblower Channel is part of the 3rd Line of Defense and is responsible for investigating allegations and providing impartial assurance, including on the effectiveness of risk management and prevention, internal controls and compliance functions.
Vale's Whistleblower Channel can be used by anyone, inside or outside the company, who wants to report a suspicion or violation of our Code of Conduct.
The channel is an exclusive platform for registering allegations, operated by an independent company and structured to guarantee:
Respect Channel Vale employees and contractors in Brazil and Canada also have access to a channel operated by a specialized, independent team, to provide support and advice to individuals experiencing harassment or discrimination. When contacting the Respect Channel, employees or contractors have the option to decide whether they wish to formally file an allegation for investigation by the Whistleblower Channel team.
Learn more about Vale’s Whistleblower Channel here.
When misconduct is confirmed, we act with fairness and transparency,in accordance with our Consequence Management Policy.
Vale's Whistleblower Channel operates independently and confidentially to ensure allegations are investigated fairly. Disciplinary measures and corrective actions are taken for any confirmed cases.
However, consequence management process is not exclusive to our Whistleblower Channel. It also applies to instances of misconduct identified in day-to-day operations. Consequence management is an additional tool for addressing ethical misconduct at Vale.